Downing, et al. v. Goldman Phipps, et al., No. 13-2345 (8th Cir. 2014)
Annotate this CaseThis case stemmed from litigation involving long grain rice producers' allegations that Bayer contaminated the United States rice supply. Plaintiff class representatives filed suit for unjust enrichment and quantum meruit against other plaintiff lawyers, alleging that these other lawyers benefited in their state court actions from litigation materials and work product generated in the MDL by the plaintiff class but refused to pay for it. The district court granted defendants' motion to dismiss for lack of personal jurisdiction. The court concluded, however, that each defendant voluntarily entered Missouri more than once to negotiate settlement of their state court cases, a settlement process which ultimately resulted in their receiving compensation as part of a settlement. Their voluntary entry into Missouri for financial benefit was both the transaction of business as that term is used in the Missouri long arm statute and constitutionally sufficient minimum contacts under the Due Process Clause. Accordingly, the court reversed and remanded.
Court Description: Civil case - Equity. In action for unjust enrichment and quantum meruit against the plaintiff lawyers in a large MDL action alleging the plaintiff lawyers benefited in their state court actions from litigation and work product generated in the underlying MDL by Downing and others but refused to pay for it, the district court erred in granting the plaintiff lawyers' motion to dismiss for lack of personal jurisdiction; where the plaintiff lawyers voluntarily entered Missouri more than once to negotiate settlement of their state court cases, their voluntary entry into Missouri for financial benefit was both the transaction of business as that term is used in the Missouri long arm statute and constitutionally sufficient minimum contacts under the Due Process Clause.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.